PRIVACY POLICY

Last Updated: 01/2017

Rodan & Fields, LLC, including all its subsidiaries and affiliates, ("Rodan + Fields," "we," "our," and "us") is concerned about privacy issues and wants you to be familiar with how we collect, use, disclose, share and protect your personal information.

Scope and Consent

You accept this Privacy Policy when you access or use the Rodan + Fields® website (or any of our international websites or applications) and any products, services software, tools, applications, features or functionality offered on or through the website or mobile application (including any Rodan + Fields Independent Consultant personal web pages provided through the website) (collectively, the “Site”). You may be accessing our Site from a computer or mobile phone device (through an iPhone or iPad application, for example) or through a Rodan + Fields mobile application, and the provisions of this Privacy Policy apply to all such mobile access and use of mobile devices. We may add additional Sites from time to time as we expand our offerings and this Privacy Policy will govern those new Sites when added.

We also like to interact with you on third-party sites where we post content or invite your feedback, including sites such as Facebook, Twitter, Pinterest and YouTube ("Third-Party Sites"). Please read the privacy policies of those social platforms, because your posts published on those platforms will no longer be governed by this Privacy Policy, except to the extent you provide or disclose your personal information via a private messaging function. In general, this Privacy Policy covers all collection, use and disclosure of your personal information, whether through the Site or otherwise.

Because our business will continue to evolve, from time to time our policies will be reviewed and may be revised. We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version of the Privacy Policy. We recommend that you review this Privacy Policy from time to time during visits to the Site and note any changes before your continued use of the Site. Your continued use of the Site after we post any revisions to this Privacy Policy constitutes your acceptance of the revised terms and conditions. It is your responsibility to periodically check this page so that you are aware of what information we collect, how we use it, and under what circumstances we might disclose it. The amended Privacy Policy will apply between us whether or not we have given you specific notice of any change. By using the Site, you agree to the terms of this Privacy Policy and our Terms and Conditions. If you do not agree to the terms of this Privacy Policy and our Terms and Conditions, please do not use the Site.

Information Collected About You

We collect the following types of personal information in order to provide you with the use of the Site and to help us personalize and improve your experience.

Information we collect automatically: When you use the Site, we collect information sent to us by your computer or mobile device. The information sent to us includes, but is not limited to, the following:

IP Addresses: Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use your IP address, and the IP addresses of all users, for purposes such as calculating Site usage levels, helping diagnose problems with the Site's servers, administering the Site, analyzing trends, including suspicious activity detection and prevention, administering the Site, tracking traffic patterns, and gathering demographic information for aggregate use. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. If you access the Site or application via a mobile device such as a smartphone, the collected information may also include your phone's unique device ID, location, and other similar mobile device data.

Environmental Variables: We and our service providers may also collect certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.

Cookies: We and our service providers may use "cookies" on the Site. Cookies are data that a web server transfers to an individual's computer for record keeping purposes. Cookies are an industry standard used by most websites, and can facilitate users' ongoing access to and use of a particular website; cookies do not cause damage to your computer systems or files. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. We are continuously working to make your experience on our Site better. To this end, we generally use Google Analytics (or other similar web analytics tool) to assist us in better understanding your use of our Site. Such web analytics tool may place cookies on your computer to collect information on our behalf that will show us how you come to our Site and how you use and navigate our Site. Some of our other business partners and service providers may also use cookies on the Site. However, we have no access to, or control over, these cookies and do not accept any responsibility for such use.

Pixel Tags: We and our service providers may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Site pages and HTML-formatted email messages to, among other things, compile aggregate statistics about Site usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors' hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.

Information you provide to us: We may collect and store any information you provide us when you use the Site. For example, when you decide to complete a user registration form, complete an online survey or make a purchase, you may be asked to provide certain information such as your contact information (name, email address, mailing address and telephone number). If you decide to place an order, we will also need to know your delivery and billing address, credit card number and expiration date. Enrolling Independent Consultants are also asked to provide their date of birth, Social Security number and other personal information, which is required in order to begin a Consultantship.

We may also collect information from or about you from other sources, such as through your contact with us, including our Sales Support Department or your results when you respond to a survey. Additionally, for quality and training purposes or for our own protection, we may monitor or record our telephone conversations with you or anyone acting on your behalf. By communicating with Rodan + Fields, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.

To protect your personal information, users registering at the Site must also enter a user name/email address and password. By making a purchase, you become a registered user of rodananddfields.com. Once you are a registered user, information required to make a purchase is stored in your account—such as your credit card number, shipping and billing addresses. If you change your mind about storing this information, you can email the Sales Support Department at salessupport@rodanandfields.com to amend or delete this information. If you would prefer that we not collect any such personal information from you, please do not provide us with any such information.

When you submit personal information on the Site, you are giving your consent to the collection, use and disclosure of personal information about you as set forth in this Privacy Policy. Please note that if you choose to share information about yourself in an open format, such as through a Third-Party Site such as Facebook or Twitter, we may consider some of that information to be public information—and not personal information.

Anonymous data: Throughout this Privacy Policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous so that it does not identify a specific user. Nor do we consider general information such as your geographic location, age group, gender, product and/or cosmetic concerns, and the brands and products that you use when you voluntarily provide such information to us, as “personal information,” when not combined with information that can be used to personally identify you or any other user.

Please note that if we combine any non-personal information with personal information, the combined information will be treated by us as personal information as long as it is so combined.

How We Use Personal Information

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:

Process transactions and send notices about your transactions. When you make a purchase through the Site, we may collect your credit card number or other payment account number, billing address and other information related to such purchase (collectively, "Payment Information") from you, and may use such Payment Information in order to fulfill your purchase.

Provide marketing information and newsletters to you regarding our products and promotions. If you prefer not to receive such emails, please see the section below entitled Choice/Opt-Out. You may receive the benefit of hearing from Rodan + Fields via postal mail or phone even if you have opted-out from receiving these marketing emails, unless you explicitly withdraw your consent to our use of your personal information as outlined in this Privacy Policy.

Permit emails to friends. We may provide functionality to permit you to send messages regarding Site-related content to a friend through the Site. If you wish to use this feature, you may provide us with your friend's email address so that we can facilitate the sending of your message to your friend.

Provide sales support.

Send administrative communications regarding the Site, service-related announcements, etc., which are necessary to serve you, respond to your concerns and to provide the high level of customer service that Rodan + Fields offers. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications unless you explicitly withdraw your consent to our use of your personal information as outlined in this Privacy Policy.

Detect, prevent or remediate violations of our Terms and Conditions or Policies and Procedures, as stated in the Consultant Agreement.

How We Share Personal Information with Other Third Parties

We may share the personal information we collect from you, including your name, contact details, and transactions and activities, in connection with:

Communications to Independent Consultants: When you submit personal information on this Site, the information that you provide may be shared with Independent Consultants if you consent by choosing to be associated with an Independent Consultant. If you choose, we may share your name, phone number, email address and order information with Independent Consultants. Independent Consultants may use this information for the purposes outlined in this Privacy Policy and in the Consultant Agreement, including to follow up on orders you placed on the Site or contact you with other special offers from Rodan + Fields.

Emails to Friends: Please note that any personal information you provide in connection with sending messages regarding Site-related content to a friend through the Site, such as your name and your email address, will of course be disclosed to your friend.

Assignment: We reserve the right to transfer any and all information that we collect from Site users to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Rodan + Fields' business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).

Other Non-affiliated Parties, including service providers, such as:

Suspicious Activity Prevention and Risk Management: to help prevent suspicious activity or assess and manage risk. For example, at the time of order, we may collect and share your email, phone number, billing and shipping addresses and device information (including IP address and geographic location) with our service provider.

Shipping: in connection with shipping products you may have ordered through the Site.

Other Service Providers: to enable service providers under contract with us to support our business operations, such as bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.

Please note that our employees and service providers may be located in foreign jurisdictions, and your personal information may be subject to the laws of those foreign jurisdictions and accessible to law enforcement and other authorities.

Third-Party Marketing

We will not provide your personal information to third parties for their use in marketing third-party products or services to you without your consent.

Law Enforcement; Emergencies; Compliance

Notwithstanding any other provision of this Privacy Policy to the contrary, we reserve the right to disclose your personal information to others as we believe to be appropriate: (a) to comply with legal process; (b) to respond to governmental requests; (c) to enforce our Terms and Conditions; (d) to protect our operations; (e) to protect the rights, privacy, safety or property of Rodan + Fields, you or others; and (f) to permit us to pursue available remedies or limit the damages that we may sustain. We may disclose any information we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request. We may also exchange information, including personal information, with other companies and organizations for credit protection and risk reduction.

Children Under 13

We comply with the Children's Online Privacy Protection Act of 1998. The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals not provide personal information through the Site. If you are under 13 years of age, you may browse our Site; however, you may not provide personal information to us. For example, you cannot register or make a purchase. This policy is designed to protect children. Federal law requires us to take special steps to safeguard children's privacy. For more information about this federal law and about children's privacy, visit the Federal Trade Commission. If you register with us and we discover that you are under 13, we will delete such registration. If you are under 13 and want to make a purchase, please ask a parent or guardian to place the order for you.

Links

The Site may contain links to third-party websites. These linked sites are not under Rodan + Fields' control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by Rodan + Fields. If you provide any personal information through any such third-party website, your transaction will occur on the third-party's website (not the Site) and the personal information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, THE INDEPENDENT CONSULTANTS.

How We Secure Your Information

We realize that our customers trust us to protect their personal information. We take that task seriously. We maintain physical, electronic and procedural safeguards to protect your personal information. We implement various security measures and tools, such as firewalls, to help protect against the loss, misuse and alteration of the information under our control. For example:

We use industry-standard Secure Sockets Layer ("SSL") authentication to guarantee the confidentiality of online transactions made on our Site. SSL authentication and encryption of the information that you send to us over the Internet help protect your online transaction information from third-party interception.

We never display your full credit card number once it is entered. We will only reveal the last four digits of your credit card for verification purposes.

Data transmission over the Internet or data storage system cannot be guaranteed to be 100% secure. There is always a risk that third parties may unlawfully intercept transmissions. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account that you might have with us has been compromised), please notify us of the problem by emailing us at privacy@rodanandfields.com.

Measures You Can Take

It is important for you to play a role in keeping your information safe and secure. When signing up for an online account, please be sure to choose an account password that is hard for others to guess and never reveal it to anyone else. If you use a shared or public computer, never choose to have your login ID or password remembered and make sure to log out of your account every time you leave the computer.

Your California Privacy Rights

Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, such as name, email and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us at privacy@rodanandfields.com. We will respond to these requests within thirty (30) days. Requests that come by other means may result in a delayed response.

California law also provides that California residents are entitled to know how the rodanandfields.com website responds to “Do Not Track” browser settings. Like many other websites and online services, this website does not currently alter its practices when it receives “Do Not Track” signals. To find out more about “Do Not Track,” and for opt-out information, you may wish to visit the Future of Privacy Forum.

Other Information

The Site is controlled and operated by Rodan + Fields from the United States, and is not intended to subject Rodan + Fields to the laws or jurisdiction of any state, country or territory other than that of the United States. Rodan + Fields does not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

Transfer of Information outside Your Home Country

Because Rodan + Fields is headquartered in the United States, we may have a need to transfer information collected from our non-U.S. customers to the U.S. We may also have a need to transfer our customer information (regardless of where you live) to other countries or places in which we maintain offices or do business. By using a Rodan + Fields website or application or by otherwise doing business with Rodan + Fields, you are agreeing to allow us to transfer your information outside your home country and to process it inside the United States or elsewhere for the purposes stated in this Privacy Policy.

Updatingand Accessing Your Information

You have the ability to change and/or correct the personal information that you provide us by emailing us at privacy@rodanandfields.com. You have the right to ask in writing whether we hold any personal information about you, to see that information, and how we collect, use or disclose your personal information. We may not be able to provide you with all the information that you request, depending on the circumstances, and there may be a charge for any copy of personal information requested. You may request that we deactivate your account by emailing us at privacy@rodanandfields.com.

Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. We also reserve the right, from time to time, to re-contact former users of the Site unless the former user has explicitly withdrawn consent. You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice. However, without your permission we may not be able to provide you with the products or services you have requested.

Choice/Opt-Out

You may opt-out of receiving future emails from Rodan + Fields when you register at the Site or otherwise provide your contact information to Rodan + Fields. Please note that this opt-out only applies to Rodan + Fields promotional emails and does not apply to communications to serve you unless you have explicitly withdrawn consent for us to use your personal information, or to other communications which may reference Rodan + Fields, e.g., from a retail store or Independent Consultant. You may opt-out of receiving Promotional Emails by emailing us at optout@rodanandfields.com. If you receive a Promotional Email and want to avoid further messages, look at the end of the email for instructions on how to remove yourself from the mailing list.

We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove personal information from the databases of Independent Consultants or third parties with which we have already shared personal information (i.e., to which we have already provided personal information about you as of the date that we implement your opt-out request). If you wish to cease receiving marketing-related emails from such Independent Consultants or third parties, please contact such Consultants or third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.

Social Commerce and Other Third Parties

We work with trusted third parties, including social network sites such as Facebook, and with application and developers who specialize in social commerce, so that we can connect to your social networks. Other social networks we use include Twitter, Pinterest, Instagram, Vine and YouTube. All of these companies operate Third-Party Sites. We provide access to our Site by third parties and business partners so that we can generate interest in our products among members of your social networks and to allow you to share product interests with friends in your network. The use of any features made available to you on our Site by a third party may result in information being collected or shared about you by us or by the third party. If you do not want us to be able to access information about you from Third-Party Sites, you must instruct Third-Party Sites not to share the information. We cannot control how your data is collected, stored, used or shared by Third-Party Sites or to whom it is disclosed. Please be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a Third-Party Site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information. Rodan + Fields is not responsible for how these third parties may use information collected from or about you. However, we do identify any areas on our Site where third parties share information about you.

Comments/Complaints

If you have any questions, comments, concerns or complaints about the Site's privacy practices, please contact us by email at privacy@rodanandfields.com or visit the Contact Us section of our website. Please note that email communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your email correspondence with us.